Traditionally, pollution
prevention (waste minimization, source reduction, etc.) has best been
represented through a hierarchy in the shape of a pyramid (below). The
information contained in this topic hub essentially follows this hierarchy when
alternatives are derived. However, in some instances, the hierarchy will not be
followed, as treatment and disposal alternatives may be the only cost-effective
options available.

Waste Management Hierarchy

Source reduction is given
the highest priority in the waste management hierarchy because avoiding waste
generation altogether, or generating the least toxic waste possible, minimizes
the problems associated with waste management. Waste that is not generated need
not be managed. Waste that is generated, but is of the lowest possible volume
and/or toxicity, can be managed most cost-effectively. Source
reduction includes, but is not limited to, material substitution, process
substitution, and process elimination. Examples of some source reduction
opportunities are described below.

Material Substitution

Materials
that will result in less toxic wastes can be substituted for materials that are
currently being used. Examples include the following:

The
substitution of less toxic drilling fluid additives will result in less
toxic drilling

wastes.

Shifting
from solvent-based paints to water-based paints reduces the toxicity of
paint wastes.

Process Substitution or Elimination

Processes
that result in less waste and increased efficiency can be substituted for
processes that are currently being used. Also, entire processes can be
eliminated if pollution prevention is implemented. Examples are use of the
following:

Well
designs and drilling methods that reduce the volume of cuttings generated,

Improved
transportation methods that reduce the risk of spills and leaks,

Improved
separation techniques at the well that eliminate the need for several gas
processing steps.

Good Housekeeping and Equipment Maintenance

Good
housekeeping and equipment maintenance are two best management practices that
are often low-cost/high-benefit approaches to pollution prevention. A common
example of good housekeeping practices involves the use of drip pans to catch
leaks or drips from equipment. Equipment maintenance is important for two
distinctly different reasons: 1) routine maintenance will reduce the occurrence
of leaks and drips, and 2) routine maintenance will extend the lifetime of the
equipment. When thinking about pollution prevention, it is important to
consider that when equipment comes to the end of its life it also becomes a
waste!

Water Conservation

Water
conservation is another best management practice which, if successful, will
greatly reduce the waste volume from oil and gas operations. Examples include

Careful use
of water during equipment cleanup and efficient operations of cooling
towers may result in reduced water volumes,

Increased
use of ?smart? pigs or ultrasonic devices to test wall thickness or detect
weak spots can enable better targeting of pipeline sections requiring
pressure testing or replacement. More efficient pigging and pre-cleaning
of pipelines prior to hydrostatic pressure testing will result in greatly
reduced volume and toxicity of waste hydrostatic test water.

Pollution Prevention in
Design and Planning

Designing
or planning for a new process or operation is the best time to address
pollution prevention considerations. With an existing process, implementing
pollution prevention can require some possible down time due to either
equipment reengineering or technician training. This will greatly add to the
cost and, therefore, reduce the economic benefit of the particular pollution
prevention approach. In the design and planning phase, there is no status quo
and, therefore, no down time and associated costs.

Training and Awareness

Training
and awareness programs are critical to ensuring that pollution prevention is
realized to its fullest potential. The best ideas will come from persons who
work with machines, use materials, and generate waste. These persons must be aware
that often there are alternatives and that they constantly need to be thinking
about ways to

improve operations,
efficiency, etc. It is always more effective to provide pollution prevention
training to persons with process know-ledge (often, the implementers and
stakeholders) than to provide ?pollution prevention experts? with process
knowledge to develop a pollution prevention plan.

Life-Cycle Analysis

Pollution
prevention often utilizes a principle known as ?life-cycle analysis? to address
all associated costs and possible solutions associated with a particular
process or waste. Life-cycle analysis, sometimes referred to as
?cradle-to-grave? analysis, is often used to

track a particular material
from its inception to its ultimate demise. This tracking usually requires
documentation from other companies (both vendors and customers) in the material
chain. In material substitution, for example, a possible material alternative
that would drastically reduce a particular waste stream may require a process
change by

the vendor first. Also, a
positive pollution prevention approach implemented by a particular company
could have negative impacts to its customers or contractors. For these reasons,
it is helpful to include vendors, customers, and contractors as part of the
pollution prevention team!

Inventory Control

Inventory
control addresses the effective use of data and information to track the
procurement, use, and management of materials throughout the operation.
Inventory control practices include the following:

?Just-in-Time? procurement. Only purchase what is
needed in the amounts needed. This is extremely important for chemicals or
materials that have relatively short shelf-lives and have to be disposed if not
used in a timely manner.

Affirmative Procurement. Only purchase
materials that have been or can be recycled. Purchase non-hazardous chemicals
and materials whenever possible.

Barcoding.
Use barcodes to track material usage throughout the facility. This is extremely
helpful in limiting the amount of material purchased if it is known how much of
that material may be already stored at the facility. Through a chemical or
material exchange program, chemicals and materials can be obtained from
operations within the facility instead of having to purchase the materials.

Unfortunately,
in some cases reduction at the source will not yet be technically possible or
economically feasible. Therefore, recycling opportunities should be investigated
for all wastes that are unavoidably generated. Recycling involves reclaiming
useful constituents of a waste material, or removing contaminants from a waste
so that it can be reused. Recycling may also involve the use or reuse of a
waste as a substitute for a commercial product, or as feedstock in an
industrial process. Recycling helps to preserve raw materials and reduces the
amount of material that requires disposal.

Treatment
should be investigated for any waste that is unavoidably generated and that
cannot be recycled in its current form. Treatment is any method, technique, or
process that changes the physical, chemical, or biological character of a
waste. Treatment renders the waste less hazardous and, therefore, recyclable or
safer to transport, store, and dispose. Note that treatment does not prevent
the creation of pollutants. Treatment involves changing the nature of the waste
or reducing or eliminating the pollutants in a waste.

Waste
treatment is usually the third option after source reduction and recycling
opportunities have been exhausted. Treatment includes techniques such as
precipitation, neutralization, stabilization, and incineration. For the
purposes of this hub, waste segregation is also considered as a treatment alternative.
In many cases, waste treatment is performed off-site by a contracting
organization. The waste generating organization must maintain very careful
records regarding the contents of the waste so the proper waste management
procedures can be carried out. In many cases, information regarding the process
that generated the waste is maintained with the waste information. This
information is helpful in demonstrating an understanding of how

(and why) the waste was generated, and it lessens the risk to
the contracting organization that may be treating wastes it may otherwise not
be permitted to treat.

Waste
segregation is an environmental best management practice designed to reduce
costs through storing incompatible wastes separately, including separating
hazardous from non-hazardous wastes, or regulated from non-regulated wastes. In
many circumstances, mixing regulated with non-regulated wastes renders the
entire waste contents regulated and unnecessarily increases waste management
costs.

Disposal

Waste
disposal generally is the discharge, deposition, injection, dumping, spilling,
leaking, or placing of any waste into or on land, water, or air. In the waste
management hierarchy, disposal is the least preferred waste management option.
Disposal also involves the greatest potential liability.

Energy Efficiency

In
most instances, energy efficiency opportunities are most prevalent in heating,
ventilation, and air conditioning systems (e.g., insulation) and in lighting.
Many of the energy efficiency best management practices address good
housekeeping principles, such as the following:

Use small lamps to direct light onto areas
where you are working.

Use dimmer switches to keep lighting down to
the level necessary.

Use outdoor lighting only when necessary. If
you do use lighting, use fluorescent globes for lights left on for extended
periods.

The
U.S. Environmental Protection Agency?s (EPA?s) A Guide to Implementing the
Natural Gas STAR Program reports a number of energy-efficient best
management practices for reducing methane emissions. The STAR Program reports
that companies involved in the program have reduced methane emissions by over
26 billion ft 3 . The

best management practices
described in the EPA guide are listed under two categories: 1) transmission and
distribution companies, and 2) production companies.